As requested, following are this office's comments on certain built-up
roofing requirements. During the performance of built-up roofing work, which
includes related sheet metal work, employees engaged in such work shall be
protected as follows:

1. By use or a motion-stopping system; or

2. By use of a warning line system supplemented with either an MSS
system or safety monitoring system; or

3. By use of a safety monitoring system on roofs fifty feet or
less in width, where mechanical equipment is not being used or
stored.

Consequently, when an employer elects to use the warning line system and/or
safety monitoring system the use of an MSS system (safety belts, guardrails,
etc.) is not required.

As stated in the preamble to the regulation, the individual designated to be
the monitor "may have supervisory or non-supervisory responsibilities as
there are no restrictions on the performance of other duties. (It is
obvious, however, that the monitor must not be so busy with other
responsibilities that the monitoring function is encumbered)." In other
words, the monitor may be a working member of the crew so long as he is on
the same roof, within visual sighting distance, and close enough to be able
to verbally communicate with the other crew member(s) when it appears that
the other crew member(s) is unaware of the hazard or is acting in
an unsafe manner.

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